Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Appellant Otha Hamilton was convicted of one count of molesting a child for an incident in which Appellant's nine-year-old step-granddaughter performed oral sex on him. Hamilton was sentenced to the maximum sentence of fifty years in prison. Hamilton appealed, arguing, inter alia, that the sentence was inappropriate given the nature of his offense and his character. The court of appeals affirmed the conviction and sentence. The Supreme Court affirmed Hamilton's conviction but revised his sentence, holding that, given the nature of Hamilton's sexual misconduct, the sentence imposed by the trial court was inappropriate. Remanded with instructions to enter an amended sentence of thirty-five years in prison. View "Hamilton v. State" on Justia Law

Jeffery Cain was convicted of murder and robbery and sentenced to life without the possibility of parole. Cain appealed his conviction and sentence, claiming that a co-defendant's testimony was improperly admitted at the guilt phase of his trial and that the prosecutor made inappropriate arguments during the sentencing phase. The Supreme Court affirmed, holding (1) under the circumstances, the trial court was well within its discretion to deny Cain's motion to exclude the co-defendant's testimony; and (2) although the prosecutor inaccurately portrayed education programs for offenders in her closing argument during the sentencing phase of Cain's trial, the prosecutor's statements did not qualify as fundamental error. View "Cain v. State" on Justia Law

Defendant Nathan Brock was charged with one count of violating Ind. Code 9-30-10-17, which makes it a felony for a habitual traffic violator to operate a motor vehicle after his or her driving privileges have been forfeited for life, and one count of felony resisting law enforcement. The trial court granted the State's motion for a mistrial due to improper prejudicial comments made by defense counsel during closing argument. Before the second trial was set to begin, Brock filed a motion to dismiss on double-jeopardy grounds. The trial court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, although Defendant did not consent to the mistrial, his second trial did not violate the Double Jeopardy Clause of the Fifth Amendment because the trial court did not abuse its discretion in concluding that a mistrial was justified by manifest necessity. View "Brock v. State" on Justia Law

Plaintiff was injured by a golf ball at a golf outing. Plaintiff filed an action against four Defendants, her grandfather, the golfer who hit the ball that struck her, a tavern that promoted the event, and the operator of the golf course. The trial court granted summary judgment in favor of each Defendant. Plaintiff appealed, claiming that genuine issues of material fact existed to preclude summary judgment on her claims of general negligence, negligent supervision, and premises liability of Defendants. The court of appeals affirmed. At issue on appeal was a sports participant's liability to others. The Supreme Court affirmed summary judgment in favor of the golfer and the golf course operator but reversed summary judgment as to the tavern and the grandfather, holding (1) a participant in a sporting event may owe a duty of care to protect others from inherent risks of the sport, and (2) summary judgment is proper due to the absence of breach of duty when the conduct of a sports participant is within the range of ordinary behavior of participants in the sport and therefore is reasonable as a matter of law. View "Pfenning v. Lineman" on Justia Law

Plaintiff, the executor of a decedent's estate, settled medical malpractice claims against several medical care providers for the decedent's wrongful death. Plaintiff then initiated this action against Defendant, the Indiana Patient's Compensation Fund, for damages that exceeded the $250,000 future value of her settlement with the medical providers pursuant to the Indiana Medical Malpractice Act. The trial court awarded Plaintiff the full amount. Defendant appealed, challenging the trial court's ruling that damages under the Adult Wrongful Death Statute (AWDS) included expenses of administration, contingent attorney fees, and loss of services. The court of appeals affirmed the trial court. The Supreme Court affirmed, holding that such damages may be sought under the AWDS. View "Ind. Patient's Comp. Fund v. Brown" on Justia Law

The parties to this lawsuit claimed rights to a punch press used in the manufacturing business of now-defunct Vitco Industries. Plaintiff, Gibraltar Financial Corporation, held a perfected security interest in Vitco's tangible and intangible property, including its equipment. Defendants, several entities including Prestige Equipment, who had acquired the press, and Key Equipment Finance, claimed that the security interest did not cover the press because the press was not Vitco's equipment, but rather, the press had been leased to Vitco by Key Equipment. The trial court granted summary judgment in favor of Defendants after concluding that the lease was a true lease. The court of appeals affirmed. The Supreme Court reversed, holding that genuine issues of material fact existed regarding whether the press was leased. The Court noted that no evidence was on the record relating to the economic expectations of Vitco and Key Equipment at the time the transaction was entered into. Remanded. View "Gibraltar Fin. Corp. v. Prestige Equip. Corp." on Justia Law

After conducting proceedings supplemental in a case on the small claims docket, the trial court ordered two self-represented judgment debtors to pay on the judgment despite their lack of non-exempt income. The court of appeals affirmed in part and reversed in part. The Supreme Court vacated the court of appeals and reversed the trial court, holding (1) courts cannot order debtors to pay out of exempt income, and (2) entitlement to the ordinary statutory exemptions at issue in this case was not forfeited by failure of the unrepresented litigants to plead them as an affirmative defense in the course of the purposefully informal small claims process. View "Branham v. Varble" on Justia Law

Mother's parental rights to her Child were terminated by the juvenile court after Mother's incarceration. The court of appeals affirmed. Mother appealed, alleging several due process violations on the part of the Department of Child Services (DCS). The Supreme Court affirmed, holding (1) if any error existed in DCS's failure to locate Mother, which resulted in Mother's absence from the termination hearing, it did not substantially increase the risk of error in her termination proceeding; (2) a misrepresentation by DCS on an affidavit, in this limited instance, did not violate Mother's due process rights; (3) a delay from DCS in serving Mother with a Child in Need of Services petition upon locating Mother was inappropriate, but a reversal was not warranted in this case because the dilatory action did not result in fundamental error or deprive Mother of due process; (4) whether an incarcerated parent is permitted to attend a termination hearing is within the sound discretion of the trial court judge, and therefore, Mother's due process rights were not violated by her absence from the trial; and (5) the evidence in this case supported the trial court's findings that termination of the parent-child relationship was in Child's best interests. View "Z.G. v. Dep't of Child Servs." on Justia Law

While driving on a county road, Pamela Price encountered ice across the roadway and lost control of her vehicle, sustaining personal injury and property damage. Earlier that morning, after a different driver lost control of his vehicle at the same location, a deputy of the county sheriff department arrived at the scene and advised the county highway department of the icy condition. Price filed a complaint against, among others, the sheriff department and highway department, alleging negligence. The sheriff department and highway department filed a motion to dismiss for failure to state a claim upon which relief can be granted, which the trial court denied. The sheriff department sought interlocutory review. The court of appeals granted review and affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the trial court, holding that because the sheriff department neither owned, maintained, nor controlled the county road, it did not owe a common law duty to warn the public of known hazardous conditions upon the roadway. View "Putnam County Sheriff v. Price" on Justia Law